An analysis of the requirements for the imposition of securities transfer tax with specific focus on the securities transfer tax consequences of a repurchase of uncertificated shares

STT is imposed on every (i) occurrence of any ‘transfer’ event (ii) of a ‘security’ (iii) that results in a change in ‘beneficial ownership’ in that ‘security’, unless that ‘transfer’ event constitutes the issue of a security or the cancellation or redemption of a security of a company that is being...

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